TFL is proud to announce that it has registered all relevant chemical substances used in its products under the EU REACH and CLP regulations. The REACH registration process, which has required substantial financial investment by TFL, ensures that TFL customers are not affected by supply problems and, as downstream users, now have access to extended product safety information via the Material Safety Data Sheet of REACH relevant products. In a small number of cases, minor product adjustments had to be made due to REACH, and in all of these TFL has worked closely with its customers to ensure the same final product quality.
EU REACH product registration, which involves a lot of testing with regards to human and environmental toxicity, is setting a high standard in chemical safety and management. EU REACH regulations and directives (incl.EU biocide product regulation) are the cornerstone in TFL’s product compliance policy. This further means that TFL is not using any current SVHC substances (substances of very high concern) in their products and also does not use those substances which are identified as SVHC and thus are listed on SVHC candidate list. In addition to the EU Reach requirements, TFL also observes the regulatory registration needs which are in place in many other countries.
Next to these legal chemical regulations, brands, manufacturers and labels have established their own lists of restricted substances to apply for finished goods (e.g. leather) or the chemical products used. Many brands have meanwhile joined the ZDHC program (Zero Discharge of Hazardous Chemicals) and aligned their requirements with the ZDHC MRSL List. This list contains around 160 chemical substances that should not intentionally be used in chemical products. TFL is a committed contributor to the ZDHC program and therefore decided to comply with the ZDHC MRSL requirements. These cover the RSL needs of most of the major brands and are established and managed by a group of industry experts and stakeholders considering the specific sectorial risks. TFL believes that working together, and having one agreed MRSL list with risk assessed limits, will save costs for our industry and allow the available resources to be spent on the elimination of the most relevant hazardous chemical substances.
Based on an internal auditing system consisting of testing and supplier management TFL declares that all products currently sold do not intentionally use substances restricted by ZDHC-MRSL and that any trace quantities will not be present at higher than the allowed final leather product RSL limits where the leather is made correctly using TFL's products.
TFL is issuing and continuously updating product compliance declarations with regards to above regulations. TFL will shortly also load all self-declared ZDHC-MRSL compliant products onto the ZDHC Gateway to allow registered users and customers to look up the status of a product. A 3rd party certification of ZDHC MRSL compliance is envisaged for 2019.